Virginia Electric and Power (Dominion Virginia Power) on April 4 filed with the Virginia State Corporation Commission (SCC) an update on its project that involves the Surry-Skiffes Creek 500-kV Transmission Line, noting that the U.S. Army Corps of Engineers on March 30 published its updated “Preliminary Alternatives Conclusions White Paper” on the project.
The company said that that white paper concluded, in relevant part: “Based on our thorough review of all information made available to date, it appears that only Dominion’s proposed project and the Chickahominy-Skiffes 500kV alternative, meet project purpose and need and are practicable. Other alternatives do not satisfy the project purpose and need and/or are not practicable due to cost, engineering constraints and/or logistics. Please note this is not a decision on whether Dominion’s preferred alternative is or is not permittable, nor does it exclude further consideration of alternatives should new information become available.”
The company noted that the Corps will make its final selection of alternatives when it issues the environmental assessment (EA), which will accompany the permit decision.
As noted in the Corps’ document, the company proposes to build a new high voltage aerial electrical transmission line, known as the Surry-Skiffes Creek-Whealton project, which consists of three components: the Surry-Skiffes Creek aerial line; the Skiffes Creek 500-kV-230-kV-115-kV switching station; and the Skiffes Creek-Whealton 230-kV aerial transmission line.
The Corps said that in total, the proposed project would permanently impact 2,712 square feet – 0.06 acres – of subaqueous river bottom and 281 square feet – 0.01 acres – of non-tidal wetlands, as well as convert 0.56 acres of palustrine forested wetlands to scrub shrub non-tidal wetlands.
As proposed, the aerial transmission lines would cross portions of the James River, Woods Creek, and Skiffes Creek, the Corps said, adding that in addition to structures being built within the James River, structural discharges are proposed in non-tidal wetlands.
The Corps said that to date, it has received numerous comments, both supporting and opposing the proposed project. Opposition has largely been due to viewshed impacts that would result from the proposed 500-kV aerial transmission line crossing the James River in proximity to nationally significant historic and cultural resources, the Corps said. The company has explored a wide range of alternatives, including burial or relocation of the proposed line, the Corps said.
Discussing the project need, the Corps noted that the company currently supplies power to the North Hampton Roads Load Area (NHRLA) through generation from the Yorktown power station – about 1,141 MW – and two transmission corridors that deliver power into the service area. The power station is comprised of two coal-fired units – Yorktown 1 & 2 – that produce about 323 MW combined, and one oil-fired unit – Yorktown 3 – that produces 818 MW, the Corps said.
With the current configuration, the company would be unable to maintain compliance with NERC standards after 2021, the Corps said.
The U.S. Environmental Protection Agency (EPA) in December 2011 passed its Mercury Air and Toxics Standards (MATS) Rule requiring power generation facilities to reduce their toxic air pollutant emissions prior to April 2015, the Corps said, noting that the Yorktown power station is subject to those required reductions.
The company plans to comply with MATS by terminating further use of Yorktown Units 1 & 2, and limiting its use of Unit 3 to 8% or less in a given year, the Corps said. The company has requested, and received, yearly extensions from the state Department of Environmental Quality and EPA. The Corps added that the EPA granted the company’s final extension – allowing Yorktown to operate only under emergency situations – under an administrative order and expires on April 15. The Corps said that it has confirmed with the EPA that the rule provides no additional time or waiver provisions beyond April.
Power load analysis using current systems and user trends demonstrate an electrical need in the NHRLA immediately following the shutdown of the Yorktown generators, and absent an improvement to the NHRLA electrical grid, the company will have to implement pre-contingency load shedding – i.e., rolling blackouts – to prevent the possibility of cascading outages impacting the reliability of the interconnected transmission system, the Corps said.
Under “alternatives considered,” the Corps noted, for instance, that new generation options throughout the area, such as combined-cycle, combustion turbine, and coal generation, were considered, as were small-scale generation sources like biomass, wind and solar. A standalone generation solution was found to be $633m, with an additional $722m required to provide sufficient infrastructure to meet NERC requirements, bringing the total cost of a new generation solution to about $1.3bn. The Corps added that new generation would also face siting, permitting, and construction timeline constraints.
Another alternative, the “Save the James Alliance Alt Solution,” includes the closing of Yorktown Unit 1 and continued operation of Yorktown Unit 2, while building a submarine 230-kV line across the James River, and building future generation facilities. The Corps added that continued operation of Yorktown Unit 2 in its present condition is not compliant with MATS, and that this hybrid alternative would require the company to run Yorktown Unit 2 in violation of MATS indefinitely or long enough to retrofit or repower one or both of the Yorktown units to develop new generation.
All alternatives, including the company’s proposed project, would, at this point, require the company to operate the Yorktown power station in violation of MATS in order to ensure uninterrupted and NERC-compliant service to the NHRLA. However, the Corps added, there is substantial difference among the alternatives in the length of time of non-compliance, and most of the alternatives reviewed would have a substantially greater cost than the company’s proposed project.
As noted in the company’s update filed with the SCC, by a November 2013 order, as modified by a Feb. 28, 2014 order and confirmed by an April 2014 order, the SCC approved the construction and operation of the proposed transmission lines and related facilities. Those orders were appealed by BASF Corporation and jointly by James City County, the Save the James Alliance Trust, and James River Association – the JCC parties – to the Supreme Court of Virginia.
The court issued its unanimous opinion on those appeals in April 2015, affirming the SCC’s approval and certification of the transmission facilities, the company added. The court’s opinion also reversed and remanded the holding in the SCC’s November 2013 order that the term “transmission line” includes transmission switching stations such as the Skiffes station under “Va. Code § 56-46.1 F,” which exempts transmission lines approved by the SCC under that section from “Va. Code § 15.2-2232” and local zoning ordinances.
The court in May 2015 denied petitions of the SCC and the company seeking rehearing of that aspect of the opinion, and, as a result, the company is required to obtain local land use approval from James City County to build the Skiffes station.
The company added that consistent with the court’s opinion, it filed in June 2015 a special use permit application (SUP), a rezoning request, a substantial accord determination request, and a height waiver application for a switching station in James City County associated with the certificated project.
The James City County Planning Commission in August 2015 voted against recommending approval of the switching station, and the company subsequently filed an appeal of the substantial accord determination to the James City County Board of Supervisors – the JCC Board.
The JCC Board will make the final determination on the SUP, rezoning and height waiver requests, and will hear the appeal on the substantial accord determination, the company added.
Among other things, the company said that it has sought – and obtained JCC Board approval for – several deferrals. With additional delays in the Corps process, the company said that it submitted another deferral request dated Nov. 14, 2016 until the June 27 JCC Board meeting, which the board approved on Nov. 22, 2016, the company said.
Dominion Virginia Power is a subsidiary of Dominion (NYSE:D).